1. Introduction
In the following, I provide information about the collection of personal data when using:
- my website your-website.com
- my profiles in social media.
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
1.1. Contact Details
The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is YOUR_NAME, YOUR_ADDRESS, YOUR_COUNTRY, email: help@your-website.com.
1.2. Scope of Data Processing, Processing Purposes, and Legal Bases
I detail the scope of data processing, processing purposes, and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
- Art. 6 para. 1 s. 1 lit. a GDPR serves as my legal basis for processing operations for which I obtain consent.
- Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g., if a site visitor purchases a product from us or I perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about my products or services.
- Art. 6 para. 1 s. 1 lit. c GDPR applies if I fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
- Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when I can rely on legitimate interests to process personal data, e.g., for cookies that are necessary for the technical operation of my website.
1.3. Data Processing Outside the EEA
Insofar as I transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g., for Great Britain, Canada, and Israel) (Art. 45 para. 3 GDPR).
If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer are usually, i.e., unless I indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4. Storage Duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e., the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
1.5. Rights of Data Subjects
Data subjects have the following rights against us with regard to their personal data:
- Right of access,
- Right to correction or deletion,
- Right to limit processing,
- Right to object to the processing,
- Right to data transferability,
- Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
1.6. Obligation to Provide Data
Within the scope of the business or other relationship, customers, prospective customers, or third parties need to provide us with personal data that is necessary for the establishment, execution, and termination of a business or other relationship or that we are legally obliged to collect. Without this data, I will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
1.7. No Automatic Decision Making in Individual Cases
As a matter of principle, I do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should I use these procedures in individual cases, I will inform of this separately if this is required by law.
1.8. Making Contact
When contacting us, e.g., by e-mail or telephone, the data provided to us (e.g., names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is my legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. I delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
1.9. Customer Surveys
From time to time, I conduct customer surveys to get to know my customers and their wishes better. In doing so, I collect the data requested in each case. It is my legitimate interest to get to know my customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. I delete the data when the results of the surveys have been evaluated.
3. Data Processing on My Website
3.1. Informative Use of My Website
During the informative use of the website, i.e., when site visitors do not separately transmit information to us, I collect the personal data that the browser transmits to my server in order to ensure the stability and security of my website. This is my legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
These data are:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software.
This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.
3.2. Web Hosting and Provision of the Website
My website is hosted by Amazon Web Services (AWS) and uses Amazon Route 53 for DNS services. The provider is Amazon Web Services, Inc., P.O. Box 81226, Seattle, WA 98108-1226, USA. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data, in the USA. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.
It is my legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
The security of the data transferred to a country outside the EEA is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which I have agreed to with the provider.
3.3. Contact Form
When contacting us via the contact form on my website, I store the data requested there and the content of the message.
The legal basis for the processing is my legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR.
I delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
3.7. Payment Processors
For the processing of payments, I use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, I thereby fulfill the contract concluded with my customers (Art. 6 para. 1 s. 1 lit. b GDPR).
These payment processors are:
- Stripe Payments Europe, Ltd., Ireland
We offer the option to process payments through the payment service provider Stripe, ℅ Legal Process, 510 Townsend St., San Francisco, CA 94103 (Stripe). This corresponds to our legitimate interest in offering an efficient and secure payment method (Art. 6 para. 1 lit. f GDPR). In this context, we transfer the following data to Stripe, as far as it is necessary for the fulfillment of the contract (Art. 6 para. 1 lit. b GDPR):
- Cardholder's name
- Email address
- Customer number
- Order number
- Bank details
- Credit card data
- Credit card expiration date
- Credit card verification number (CVC)
- Date and time of transaction
- Transaction amount
- Provider's name
- Location
The processing of the data specified in this section is neither legally nor contractually required. Without the transmission of your personal data, we cannot process a payment via Stripe. [You have the option to choose a different payment method.]
Stripe assumes a dual role as both a controller and a processor in data processing activities. As a controller, Stripe uses your transmitted data to fulfill regulatory obligations. This corresponds to Stripe's legitimate interest (according to Art. 6 para. 1 lit. f GDPR) and serves to fulfill the contract (according to Art. 6 para. 1 lit. b GDPR). We have no influence on this process.
As a processor, Stripe functions to complete transactions within payment networks. Within the scope of the processing relationship, Stripe acts exclusively according to our instructions and has been contractually obligated to comply with data protection regulations in accordance with Art. 28 GDPR.
Stripe has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).
For more information on objection and removal options regarding Stripe, please visit: https://stripe.com/privacy-center/legal
We store your data until the completion of the payment processing. This includes the period necessary for processing refunds, claims management, and fraud prevention. [For us, according to [§ 147 AO / § 257 HGB], there is a legal retention period of [X] years for the following documents: [ ]]
Legal notices
Address
Stripe Payments Europe Limited 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland Attention: Stripe Legal
3.2. Web Hosting and Provision of the Website
My website is hosted by Amazon Web Services (AWS) and uses Amazon Route 53 for DNS services. The provider is Amazon Web Services, Inc., P.O. Box 81226, Seattle, WA 98108-1226, USA. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data, in the USA. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.
It is my legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
The security of the data transferred to a country outside the EEA is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which I have agreed to with the provider.
We use the Content Delivery Network (CDN) Amazon CloudFront from Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855 Luxembourg (AWS) to increase the security and delivery speed of our website. This corresponds to our legitimate interest (Art. 6 para. 1 lit. f GDPR). A CDN is a network of [globally] distributed servers that can optimally deliver content to website users. For this purpose, personal data may be processed in AWS server log files. Please refer to the information under "Hosting". [Additionally, we retain [anonymized] log files to ensure [optimize] the stability and security of our website.] AWS is the recipient of your personal data and acts as a processor for us. This corresponds to our legitimate interest within the meaning of Art. 6 para. 1 s. 1 lit. f GDPR in not operating our own content delivery network. You have the right to object to the processing. Whether the objection is successful must be determined as part of a balancing of interests. The processing of the data specified in this section is neither legally nor contractually required. The functionality of the website is not guaranteed without the processing. Your personal data will be stored by AWS for as long as necessary for the purposes described. [We delete the stored log files after [ ]]. For more information about objection and removal options regarding AWS, please visit: https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf AWS has implemented compliance measures for international data transfers. These apply to all global activities where AWS processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs). For more information, please visit: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf
3.8. Technically Necessary Cookies
My website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of my website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. I have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, I set technically necessary cookies for the following purpose or purposes:
- Cookies that store language settings, login data, and payment provider data for payment processing without analyzing user behavior.
3.9. Third Parties
3.9.1. PostHog
I use PostHog for product analytics. The provider is PostHog, Inc., 965 Mission St, San Francisco, CA 94103, USA. The provider processes usage data (e.g., web pages visited, interest in content, access times), content data (e.g., entries in online forms), and meta/communication data (e.g., device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. I have a legitimate interest in understanding user behavior to improve my services.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://posthog.com/privacy.
4. Data Processing on Social Media Platforms
I are represented in social media networks in order to present my organization and my services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g., because it is more difficult to enforce their rights or because government agencies access the data.
If users of the networks contact us via my profiles, I process the data provided to us in order to respond to the inquiries. This is my legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
5. Changes to This Privacy Policy
I reserve the right to change this privacy policy with effect for the future. A current version is always available here.
6. Questions and Comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.
Last updated: 2024-08-05